Required documentation of test results for Type A packaging- aREPLY

[schadt@interserv.com]

Bruce Pickett -- The following is in reply to your post regarding 
Type A quantity being shipped back to the manufacturer and your 
requirement that you have the engineering drawings for the Spec 
55 packaging that was recertified as Type A.

49CFR178.601 is included in Subpart M, "Testing of Non-bulk 
Packagings and Packages."  Subpart M includes 178.601 through 
178.609.  You are shipping a bulk package not a non-bulk package. 
Thus, Subpart M does not apply in your case. Your reference to 
173.601 is not appropriate because 173.601 does not apply in your 
case. Type A packages are covered under both Subparts I and K and 
neither I nor K include any references to Subpart M.  If a 
request for Subpart M information (test results, drawings, etc.) 
is not compatible with Subparts I and K requirements, there is no 
way the manufacturer can provice the information -- they don't 
have it and never needed to have it.  If drawings do exist, and I 
assume that they do, the DOT requlations do not require that they 
be provided to you by the manufacturer.

In 173.415 it states that "Each shipper of a Spec 7A package must 
maintain on file for at least one year after the latest shipment, 
and shall provide to the DOT on request, a complete documentation 
of tests and an engineering evaluation OR COMPARATIVE DATA 
showing that ... comply with that specification."  173.415 does 
not require the shipper (or the manufacturer) to provide 
packaging design or drawings.  Only the documentation of tests 
(which I assume are the 7A test results sent to you) or 
comparative data.

	Has the manufacturer sent you the DOT 55 specification 
information under which this package was originally built?  
Normally, Spec 55 containers far exceed any current Type A 
package specification and should easily suffice as the 
comparative data section of the shipper's documentation 
requirement.

	The following is a brief summary of applicable parts of 
10CFR49.

Radioactive material n.o.s. [normal form or A(2) quantity of RAM]
   Exceptions: reference 173.421, 422 and 424
   Non-bult packaging: reference 173.415 and 416
   Bult packaging: reference 173.415 and 416
Radioactive material, special form, n.o.s. [Special form or A(1) 
quantity of RAM]
   Exceptions: reference 173.421 and 422
   Non bulk packaging: reference 173.415 and 416
   Bulk packaging: reference 173.415 and 416

Note regarding 49CFR.  Radioactive materials are HAZARD CLASS 7 
hazardous materials.  Class 7 materials have their own subparts 
for compliance and are NOT SUBJECT TO COMPLIANCE MEAURES IN 
SUBPARTS NOT PERTAINING TO CLASS 7.

Subpart K - Specifications for packaging for CLASS 7 Radioactive 
materials includes 49CFR178.350 through 178.364-6.
   This Subpart covers the package specificatns for the following 
Radioactive Materials Packages: 7A, 6L, 6M, 20PF, 21PF, 21PF-1, 
21PF-1B, 2R, 20WC and 21WC.
 



Sincerely,

Bill Schadt   (301) 622-9644 (voice)
              (301) 622-1582 (fax)
              schadt@interserv.com